Response to consultation on draft Guidelines on the sound management of third-party risk
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Question n. 1 for Public Consultation: Are subject matter, scope of application, definitions and transitional arrangements appropriate and sufficiently clear?
The Scope of application should be clarified: We would like to understand whether No. 13 (3. Background and rationale) means that PSPs can be excluded when their service is subject to regulation, i.e. they are licensed in a similar way as DORA030 - 2999 clarified.
Relating to the sentence: The use of third-party arrangements between credit institutions, payment institutions, investment firms, and such entities are within the scope of the Guidelines when such entities act as TPSPs